1. U.S. DOT Pipeline and Hazardous Materials Safety Administration Distribution Integrity Management Update Tuesday, August 23, :15-11:00 AM Western Region Gas Conference Chris McLaren

2. Today’s Topics Performance Based Regulations Drivers for DIMP
DIMP Inspections Lessons Learned
Incidents trends
Current Topics

3. Performance Based Regulations
Historically, regulation have been prescriptive providing tasks that must be completed to meet established minimum safety requirements
Performance based regulations provide a framework that an operator tailors to meet their unique operating environment to meet objectives
Programs are expected to mature and be continuously improved and worked on
Prescription is added to performance based IM regulations as time goes by to address inadequacies identified in inspections and accident investigations

4. Management Systems
PHMSA has worked on Pipeline Risk Management Systems since 1990’s
In the 1990’s, PHMSA completed the Risk Management Demonstration & Systems Integrity Projects
2000’s - Integrity Management (IM) Regulations promulgated for Hazardous Liquid and Gas Transmission pipelines
2010’s – IM Regulations promulgated for Gas Distribution and Hazardous Liquid Gathering pipelines
PHMSA has continuously evaluated the implementation of the IM regulations and sought to clarify and improve them thru Rulemaking and Stakeholder Communication

5. Management Systems
A framework of policies, processes and procedures used to ensure that an organization can fulfill all tasks required to achieve its objectives.
Include accountability (an assignment of personal responsibility) and a schedule for activities to be completed, as well as auditing tools to implement corrective actions, creating an upward spiral of continuous improvement.
A simplified model is the P-D-C-A "Plan, Do, Check, Act/Adjust“ cycle of continuous improvement.
A-D-D-I-E Model is another way to describe a continuous improvement cycle –
Analyze, Design, Develop, Implement, & Evaluate

7. Moving from Compliance to Choice
Our world must move from a “checkbox” mentality to understanding the health of our pipeline systems by analyzing and understanding data and information and promptly acting to reduce risks
Safety culture is a term commonly used as a mechanism to change operator behavior from minimum compliance standards towards choosing to do the “right thing” for the safe operation and integrity of the pipeline system
Safety Management Systems are just one type of Management Systems implemented or discussed by PHMSA – Integrity, Quality, Risk

8. DIMP Home

9. National Drivers Continue to Place the Focus on Gas Distribution
Vintage Pipe Materials
US DOT Call to action
Continued Incidents involving Cast Iron Mains
DIMP
Methane Emissions
PHMSA Research and Development Activities

10. Vintage Pipelines
The term “Vintage Pipelines” commonly refers to pipe installed prior to the 1970’s.
Pipe making and construction practices that are no longer used, including some early variations of current practices, are termed historic. Vintage pipelines are those built using pipe or construction practices made with such historic practices.
Different for Transmission and Distribution in some respects, but used across both.
For Distribution Infrastructure - cast and wrought iron mains, certain vintages of plastic pipe and mechanical coupling installations, bare steel pipe without adequate corrosion control, and copper piping.

11. Aging Pipelines
Pipeline transportation is one of the safest and most cost-effective ways to transport natural gas and hazardous liquid products.
As the United States continues to develop and place more demands on energy transportation, it becomes necessary to invest in upgrading its infrastructure, including aging pipelines.
Among other factors, pipeline age and material are significant risk indicators. Pipelines constructed of cast and wrought iron, bare steel, and other vintage plastics are among those pipelines that pose the highest-risk
In 2011, following major natural gas pipeline incidents, DOT and PHMSA issued a Call to Action to accelerate the repair, rehabilitation, and replacement of the highest-risk pipeline infrastructure.

12. US DOT Secretary Call to Action
In March 2011, former Secretary of Transportation Ray LaHood and PHMSA issued a Call to Action to engage all the state pipeline regulatory agencies, technical and subject matter experts, and pipeline operators in accelerating the repair, rehabilitation, and replacement of the highest-risk pipeline infrastructure.

13. Call to Action Highlights
Letters requesting for assistance with Cast Iron Replacement to Governors, State Regulators (NAPSR) & Commissioners (NARUC)
Letters to Industry
Letters to Technical, Safety, and Environmental Organizations
Letters to Local and State Organizations
Letter to Federal Energy Regulatory Commission (FERC)
White Paper on State Replacement Programs
Request for State Governors’ Assistance with Cast Iron Replacement
Call to Action - Action Plan

14. Progress in Modernization
Gas Distribution Cast/Wrought Iron Main Miles and Service Count Trend
More progress is needed in accelerating replacements

15. Serious Gas Distribution Incidents
Distribution System Type have plateaued
Serious – fatality or injury requiring in-patient hospitalization

16. Significant Incidents
Distribution System Type have plateaued/rising trend
In last 10 years, 70,000 miles of transmission and 200,000 miles of distribution have been constructed
This data is not normalized by miles of pipe
Significant includes Serious incidents as well as incidents costing $50,000 or more in total costs, measured in 1984 dollars; Highly volatile liquid (HVL) releases of 5 barrels or more; Non-HVL liquid releases of 50 barrels or more; or Liquid releases resulting in an unintentional fire or explosion

17. All System Type rises slightly in 2014 and have plateaued
Serious Incidents
All System Type rises slightly in 2014 and have plateaued
Serious – fatality or injury requiring in-patient hospitalization

18. Significant Incidents
All System Types have plateaued/rising trend
In last 10 years, 70,000 miles of transmission and 200,000 miles of distribution have been constructed
This data is not normalized by miles of pipe
Significant includes Serious incidents as well as incidents costing $50,000 or more in total costs, measured in 1984 dollars; Highly volatile liquid (HVL) releases of 5 barrels or more; Non-HVL liquid releases of 50 barrels or more; or Liquid releases resulting in an unintentional fire or explosion

19. Distribution IM Impact
The regulation requires distribution operators to develop and implement a distribution integrity management program with the following elements:
Knowledge
Identify Threats
Evaluate and Rank Risks
Identify and Implement Measures to Address Risks
Measure Performance, Monitor Results, and Evaluate Effectiveness
Periodically Evaluate and Improve Program
Report Results

20. Knowledge
Data quality is a common concern, and an appropriate level of resource allocation is required;
Outdated, incomplete, obvious errors.
Outdated data systems difficult to use or sort.
Data cleanup and scrubbing is often required.
Field data acquisition forms and internal IT processes to incorporate new information and correct inaccurate information may need to be modified.
Procedures for identification and collection of additional and missing information must be included in DIMP to ensure consistent collection and processing.

21. Identify Existing and Potential Threats
§ What are the required elements of an integrity management plan? A written integrity management plan must contain procedures for developing and implementing the following elements: (b) Identify threats. The operator must consider the following categories of threats to each gas distribution pipeline: Corrosion, natural forces, excavation damage, other outside force damage, material or welds, equipment failure, incorrect operations, and other concerns that could threaten the integrity of its pipeline. An operator must consider reasonably available information to identify existing and potential threats. Sources of data may include, but are not limited to, incident and leak history, corrosion control records, continuing surveillance records, patrolling records, maintenance history, and excavation damage experience.

22. Potential Threats
Some Operators struggle with potential threats beyond existing threats that are important
Threats the Operator has not previously experienced (from industry or PHMSA information)
Threats from aging infrastructure and materials with identified performance issues may need to be considered existing threats depending on the materials in question and the operating environment
Threats that endangered facilities but have not resulted in a leak (e.g., exposed pipe, near misses).
Non-leak threats (overpressure, exposure, outside force)
Manufacturing and Construction Threats
Maintenance history

23. Evaluate and Rank Risks
System subdivision for the evaluation and ranking of risks must be sufficient to appropriately analyze risk(s) present in the Operator’s unique operating environment.
Geographical segmentation may be appropriate when systems are separated by space or a specific, predominate threat exists (e.g., where flooding can be expected, earthquake prone area, uniform construction).
However, materials or construction may be the predominate threat(s) in a region, and segmentation may need to be refined to accommodate different failure rates to adequately differentiate and identify significant potential and existing threats.

24. Identify and Implement Measures to Address Risks
Replacement of Vintage Materials is a Priority to PHMSA, and acceleration in any established replacement programs is warranted
Increased Leak Survey Frequency to identify emerging threats
Establish replacement schedules to Repair or replace the problem materials or equipment.
Monitor coupons & internal pipe conditions when cut (bell hole report)
Correct cathodic protection deficiencies
Evaluate gas supply inputs and take corrective action with supplier

25. Performance Measurement
A DIMP must include procedures for establishing baselines and monitoring Performance Measures required in (e) –
Total number of leaks and the Number of hazardous leaks either eliminated or repaired categorized by cause
Number of hazardous leaks either eliminated or repaired categorized by material
Number of excavation damages and tickets
Operators must develop and monitor performance measures from an established baseline to evaluate the effectiveness of its IM program.
Each Activity Implemented to Reduce Risk must have a Performance Measure established to monitor its effectiveness

26. Periodic Evaluation and Improvement
(f) Periodic Evaluation and Improvement.
An operator must re-evaluate threats and risks on its entire pipeline and consider the relevance of threats in one location to other areas.
Each operator must determine the appropriate period for conducting complete program evaluations based on the complexity of its system and changes in factors affecting the risk of failure.
An operator must conduct a complete program re-evaluation at least every five years.
The operator must consider the results of the performance monitoring in these evaluations.

27. Continuous Improvement is the Goal and a Requirement of IM Programs
Safety Management Systems - Plan, Do, Check, Act - The core of SMS in API RP 1173
Continuous Improvement is the Goal and a Requirement of IM Programs

28. Management Systems are Effective
Management Systems require More
Intentional and systematic actions
Diligence and oversight
Involvement at all levels - communications
“Go and Check” attitude
The rewards of Management Systems are
Increased pipeline safety – risk reduction
Creation/Enhanced safety oriented culture
Broader organizational involvement

29. Leadership is everywhere
Top Management- accountable for continuous improvement, routine review of safety performance and communications about safety
Management- ensures process, procedures and training to meet objectives; assess, evaluate and adjust as needed to meet objectives; foster continuous improvement
Employees– identify improvements, reveal risks
Consider employee, public and pipeline safety when stopping work for safety concern
Bring rigor of employee safety to asset protection
Plan Do Check Adjust

30. Why Not Regulate SMS?
If PSMS is So Great, Why Isn’t PHMSA Turning it into a Regulation?
The Regulatory Process is SLOW.
The Industry (people and organizations) needs to embrace the concept, not just the letter of a law.
Many executives from various industries believe SMS is the right thing to do AND it is financially viable (insurance, etc.)
Advice from Chris Hart, Chair – NTSB, and FAA
“Collaboration is absolutely essential – or SMS implementation will not be successful”

31. SMS Where are we today
Increased focus on Integrity Management Systems especially the “later TIMP protocols”
Performance Measurement
Continuous Improvement
Management of Change
Communication
Quality Assurance
Training PHMSA Inspectors in auditing techniques - different from inspection techniques for compliance to minimum safety requirements of prescriptive regulations
Supports IM training for inspection of performance based rules
Supporting industry workshops and conferences on SMS and their design, development, and implementation
Industry is performing gap analyses on operators’ management systems to identify areas for improvement

32. PHMSA Form 24
NAPSR and PHMSA are looking to incorporate field investigation and verification of the Operator’s DIMP Implementation into regulatory inspection programs with the new “Records and Field Implementation” Inspection Form
PHMSA Form 24 is for the evaluation of an operator’s implementation of its DIMP through a review of its records and actions performed on pipeline facilities.
Intended for inspections of Implementation of DIMP after initial DIMP inspections
The form asks inspectors to review records and perform field observations regarding the implementation of the required DIMP elements.

33. PHMSA Form 24 Example

34. Form 24 – 1007(f) section

35. Form 24 – 1007(f) section

36. Form 24 – 1007(f) section

37. Mechanical Fitting Joint Failure Reporting
Communication of Performance Data is through the DIMP web page. To view MFFR data, go to:
Total Report Submitted Numbers (08/01/2016):
MFFRs submitted for 2011 – 8,342
MFFRs submitted for 2012 – 7,607
MFFRs submitted for 2013 – 9,920
MFFRs submitted for 2014 – 11,718
MFFRs submitted for 2015 – 12,854
Data submitted for 2015 shows similar trends to previous 4 years of data collection.

38. MFJFR Data Analysis
Mechanical Joint Failures are being identified in many DIMPs as a significant threat requiring risk mitigation measures.
6.0% of hazardous leaks eliminated/repaired in 2015 involved a mechanical fitting
The majority of mechanical joint failures resulting in a hazardous leak involve nut-follower, coupling types.
Steel fittings are involved the majority of reports, and plastic fittings are second.
The majority of leaks occur outside, belowground involving service-to-service connections.
Equipment failure is the leading reported cause of leaks, and Natural forces is second.

39. Climate Change Impact Growing focus on mitigating fugitive methane
EPA to potentially regulate LDCs via the Clean Air Act
Studies by the Environmental Defense Fund illustrate volumes released by LDCs and that replacement/rehabilitation of old pipe breeds rapid/large reductions

40. Mitigating Fugitive Methane
PHMSA closely following issues and policy development by others - White House, Congress and Industry
Coordinating with EPA with data sharing, meetings and PHMSA participation at EPA Gas Star Program events
Coordinating with the Environmental Defense Fund efforts and added EDF representation on PHMSA’s congressionally mandated Pipeline Advisory Committee
Reviewing natural gas regulations to understand leak paths and possible actions germane to our statutory mission
However, safety case largely already made in support of hazardous leak reductions
Remaining non-hazardous leaks generally economic in nature
NARUC, FERC and the Congress

41. Downstream Natural Gas Initiative
The Downstream Natural Gas Initiative is a group of natural gas utilities collaborating to address key technical and regulatory factors affecting methane emission reduction opportunities from natural gas distribution systems.
Partners will work to identify and encourage programs that accelerate investments in infrastructure and promote outstanding operations, including modernizing their systems, utilizing next generation technologies, and quantifying emissions.
The initiative is focused on opportunities that can substantially reduce methane emissions and support safe, reliable, and cost-effective service

42. PHMSA R&D on Methane Emissions
Emissions Quantification Validation Process
The main objective of this project is to identify, apply and test a methodology or methodologies that validate quantified methane emissions rate measurements in gas distribution systems. This project will build on current and evolving understanding related to the practical application of methane emissions quantification technologies for non-hazardous grade 3 leaks.
If successful in validating a technology or combination of technologies that can apply to accurately quantify methane emissions, the proposed effort would allow more data driven decisions based on the greenhouse gas emissions contribution of individual non-hazardous leaks. This validated quantitative flow rate information could aid in prioritization of repair decisions.

43. Risk Analysis Application in IM
Integrity Management is a Performance based Risk Management Program
Risk Models and Assessments are required to be used throughout the IMP
Baseline Assessment
Data Integration / Information Analysis
Preventive Measures Determinations
Mitigative Measures Determinations
Continuing Evaluation and Assessment

44. NTSB and Others’ Comments
On Risk Methodologies
Risk evaluation methods must be sufficiently analytical to be predictive (NTSB Investigations and Safety Study)
Threats on a particular line segment increasing or decreasing?
Consequence potential increasing?
Interactive threat potential becoming a major issue?
Industry and PHMSA are in general agreement that risk models need to evolve in such a way as to be more investigative in nature
As summarized and discussed in past public forums and workshops on pipeline safety (e.g., 2014 Government/Industry Pipeline R&D Forum)

45. Sufficiently Analytical to be Predictive
Do Results reflect year-to-year changes in risk levels?
Operational, Environmental, Assessments
Does the overall risk profile adequately match operational experience?
Approaches may need to vary between respective types of threats (time dependent/independent)
More complex does not necessarily mean better
Interactive threats may need more sophisticated modeling than threats evaluated individually

46. Connection to Decision Making
Risk evaluation results must have a connection to real-life decision making
Point of risk evaluations is not to do a risk evaluation
Risk insights must be integrated into routine integrity-related decision making
Operators should be able to easily demonstrate how risk evaluation results influence work practices

47. Risk Modeling Meeting website http://primis.phmsa.dot.gov/meetings/

48. Risk Modeling Work Group (RMWG)
The PHMSA Pipeline Risk Modeling Work Group was formed as a follow up to the September Pipeline Risk Modeling Methodologies Public Workshop
The purpose of the group is to provide technical, integrity management and operational input to PHMSA to aid in the development of a pipeline system risk modeling technical guidance document

49. Risk Modeling Work Group
PHMSA is seeking a wide range of input and consensus as part of the development of this technical guidance, both from within, and from applicable stakeholders
There are approximately 30 members from the regulatory, operator, and interested party communities
This work group provides a forum to obtain the combined perspective of industry, regulators, public, and risk services providers, and it will also provide a mechanism for eventual public input/comment

50. RMWG Mission Statement
The mission of the Risk Modeling Work Group (RMWG) is:
Characterize the state of the art of pipeline risk modeling for gas transmission and liquid pipelines,
Identify and, if necessary in specific areas, develop a range of state-of-the-art methods and tools capable of addressing the spectrum of pipeline risk management applications, and
Provide recommendations to PHMSA regarding the use of these methods, tools, and data requirements

51. Risk Modeling Work Group
PHMSA has identified a need to provide technical guidance on
Methods, and tools to be used in pipeline risk modeling, and
Application of these methods and tools in pipeline risk management.
PHMSA’s technical guidance needs to be based on the state of the art of pipeline risk modeling, as reflected in the views of the technically informed community of practice

52. RMWG Guidance Document
Following several RMWG meetings, a Guidance Document will be published in the Summer, 2017, covering the following:
Regulatory Requirements for Risk Analysis Performance
How Risk Modeling Fits into Overall Pipeline Risk Management
Likelihood Modeling
Consequence Approach Selection
Facility Risk Approach Selection
Risk Modeling Data Needs

53. PHMSA Websites
Please regularly use PHMSA websites as they are a primary form of communication with Stakeholders
PHMSA Office of Pipeline safety
DIMP Home Page
Pipeline Safety Stakeholder Communications
Pipeline Replacement Updates

54. Thank you for Your participation in Pipeline Safety